1. Purpose and Scope
This document sets out the anti-money laundering (AML) and know your customer (KYC) policy applied by Grosvenor Casino Bayswater. It describes the legal framework under which identity verification and financial monitoring obligations arise, the procedures followed to meet those obligations, and the responsibilities that apply to customers and to the casino operator.
This policy applies to all individuals who access or use the services of Grosvenor Casino Bayswater. It is maintained in accordance with the requirements of the UK Gambling Commission and applicable UK legislation. The policy is reviewed and updated on a regular basis to reflect changes in regulatory guidance and industry risk assessments.
2. Legal and Regulatory Framework
Grosvenor Casino Bayswater operates within a regulatory environment that imposes specific AML and counter-terrorist financing obligations on casino operators. The principal legislative instruments governing these obligations are:
- The Gambling Act 2005
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (the MLRs)
- The Proceeds of Crime Act 2002 (POCA)
- The Terrorism Act 2000
As a casino operator, Grosvenor Casino Bayswater falls within the regulated sector for AML purposes under the MLRs. This means it is subject to the full scope of customer due diligence, enhanced due diligence, record-keeping, and reporting requirements set out in those Regulations, in addition to the Licence Conditions and Codes of Practice (LCCP) issued by the UK Gambling Commission.
Licence Condition 12.1.1 of the LCCP requires casino operators to have documented AML and counter-terrorist financing policies, procedures, and controls in place, to implement them effectively, and to keep them under review in line with Commission guidance and published risk assessments.
3. Risk Assessment
A formal, documented assessment is maintained of the money laundering and terrorist financing risks posed by the business activities and customer base of Grosvenor Casino Bayswater. This assessment is reviewed periodically and updated whenever material changes occur in operations, customer profile, or the regulatory environment.
The risk assessment takes into account the UK Gambling Commission’s published industry-wide risk assessments, including those specific to casino operations, and the guidance of the Financial Action Task Force (FATF), which identifies casinos as a higher-risk sector for money laundering globally.
4. Customer Due Diligence
4.1 Standard Due Diligence
Customer identification and verification is required before or during the establishment of a business relationship, and in certain transaction-based circumstances regardless of whether an ongoing relationship exists.
For casino token purchases or exchanges, and for gaming machine use, customer identification and verification is required when a customer purchases, exchanges, or collects tokens or winnings amounting to €2,000 or more in a single transaction or in a series of linked transactions.
For remote gaming activity, customer due diligence applies when a customer deposits, withdraws, or otherwise transacts €2,000 or more for gambling purposes, whether in a single operation or through linked transactions.
These thresholds represent minimum triggers. Due diligence may be applied at lower levels where risk indicators are present.
Standard customer due diligence measures include:
- Identifying the customer and verifying their identity using reliable, independent documents or electronic data sources
- Understanding the nature and intended purpose of the business relationship
- Conducting ongoing monitoring of transactions and activity throughout the relationship
4.2 Enhanced Due Diligence
Enhanced due diligence and enhanced ongoing monitoring are required in circumstances that present a higher risk of money laundering or terrorist financing. These circumstances include, but are not limited to:
- Situations identified by Grosvenor Casino Bayswater or by the UK Gambling Commission as presenting elevated risk
- Business relationships or transactions involving customers from, or connected to, high-risk third countries as designated under applicable UK guidance
- Customers who are politically exposed persons (PEPs), or who are family members or known close associates of PEPs
- Cases where false or stolen identification documents are discovered and continuation of the relationship is under consideration
- Transactions that are unusually large, unusually complex, follow unusual patterns, or have no apparent economic or legal purpose
Enhanced measures may include obtaining additional information about the customer and their source of funds, further information about the purpose and nature of the relationship, more detailed scrutiny of transaction patterns, and approval from senior management before proceeding.
4.3 Electronic Verification
Electronic identity verification tools may be used to fulfil AML and KYC obligations. Customers are informed that such checks will take place. These checks are conducted for AML and counter-terrorist financing purposes and leave a different footprint from credit reference searches. Customer consent is not required for these checks, but disclosure that they occur is required.
5. Ongoing Monitoring
Ongoing monitoring of customer activity is carried out throughout the business relationship. This includes scrutiny of transactions to ensure they are consistent with existing knowledge of the customer, their stated source of funds, and their risk profile. Where activity is inconsistent with the established profile, or where new risk indicators emerge, due diligence measures are reviewed and updated accordingly.
Grosvenor Casino Bayswater does not rely on third-party payment processors or other third parties to conduct KYC checks or to establish source of funds on its behalf. Responsibility for ensuring adequate customer checks remains with the casino operator.
6. Suspicious Activity Reporting
There is a legal requirement to report to the UK National Crime Agency (NCA) when there is knowledge, suspicion, or reasonable grounds to suspect that a person is engaged in money laundering or terrorist financing. This obligation arises under Part 7 of POCA and the relevant provisions of the Terrorism Act 2000.
Internal procedures are maintained for staff to escalate concerns to the nominated Money Laundering Reporting Officer (MLRO). The MLRO evaluates internal reports and, where appropriate, submits Suspicious Activity Reports (SARs) to the NCA in accordance with the UK Gambling Commission’s published guidance on SAR submission.
Staff are trained to recognise indicators of suspicious activity and to understand the process for making internal reports. Procedures are in place to ensure that customers are not tipped off when a SAR has been filed or is under consideration.
7. Internal Controls and Governance
Internal systems and controls are maintained to allow Grosvenor Casino Bayswater to respond fully and promptly to enquiries from the NCA, financial investigators, law enforcement, and other competent authorities regarding customer transactions and account history.
The AML and KYC framework is subject to regular internal review and audit. Staff who handle customer accounts or transactions receive training on AML obligations, red-flag indicators, and internal reporting procedures. Training is updated to reflect changes in legislation, regulatory guidance, and identified risk areas.
Indicators of problem gambling and indicators of money laundering or terrorist financing can overlap. Internal procedures are designed to ensure that these risk areas are considered together rather than in isolation.
8. Record-Keeping
Records of customer identification documents, verification data, transaction history, and due diligence assessments are retained for the periods required under the MLRs and UK Gambling Commission guidance. These records are maintained securely and made available to competent authorities upon lawful request.
9. Policy Review
This policy is reviewed at regular intervals and updated to reflect changes in the UK Gambling Commission’s guidance, published risk assessments, and applicable legislation. Customers may be subject to additional verification or monitoring requirements if the policy is updated in a way that affects their risk classification or the scope of checks applied to their account.